The First Circuit, in a closely watched securities case, reversed a $93 million summary judgment ruling for the Securities and Exchange Commission this April. ...more
We are actively looking for circumstances where an adviser is financially conflicted by incentives that could affect investment recommendations to clients. ... And I will tell you: the more we look, the more undisclosed or...more
SEC Proposes to Update Accredited Investor Definition to Increase Access to Investments - On December 18, 2019, the Securities and Exchange Commission (SEC) proposed amendments to the definition of “accredited investor” in...more
In Robare Group v. SEC, the court clarified the meaning of “willfully” under Section 207 of the Investment Advisers Act of 1940. A willful omission requires that a person “subjectively intended to omit material information.”...more